23ph Privacy Policy

1. Introduction

This Privacy Policy ("Policy") applies to all personal data collected and processed by 23ph ("23ph," "we," "us," "our") through the 23ph website, mobile browser platform, games, payment systems, customer support channels, and all associated services (collectively, the "Service").

23ph is committed to protecting the privacy and security of all users ("you," "Player," "User") in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012, and its Implementing Rules and Regulations (IRR), as well as all applicable regulations issued by the National Privacy Commission (NPC) of the Philippines.

By creating a 23ph account, accessing the platform, or using any part of the Service, you confirm that you have read, understood, and consented to the collection, use, storage, and sharing of your personal data as described in this Policy.

2. Data Controller

23ph is the data controller for all personal data processed through the Service. As the data controller, 23ph determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable data protection laws.

If you have questions or concerns about how 23ph processes your personal data, or wish to exercise your data subject rights under the Data Privacy Act of 2012, please contact us using the details provided in Section 15 of this Policy.

3. What Personal Data We Collect

23ph collects the following categories of personal data necessary to provide the Service, comply with regulatory obligations, and protect the security and integrity of the platform:

4. How We Collect Your Personal Data

23ph collects personal data through the following methods:

• Direct Collection: Information you provide directly to 23ph during account registration, KYC verification, payment processing, customer support interactions, and when configuring account settings.
• Automatic Collection: Technical data collected automatically through cookies, server logs, and analytics tools when you access and use the 23ph platform.
• Third-Party Collection: Payment processing data received from GCash, Maya, BPI, BDO, UnionBank, Metrobank, Coins.ph, and USDT payment networks when you fund or withdraw from your 23ph wallet.
• Game Provider Collection: Gameplay data received from third-party game providers whose content is integrated into the 23ph platform (live casino providers, slot developers, sports betting data providers).

5. How We Use Your Personal Data

23ph processes your personal data for the following purposes:

• Account Management: To create, maintain, and secure your 23ph account; to authenticate your identity; and to provide access to the Service.
• Payment Processing: To process deposits to your 23ph wallet and withdrawals to your verified payment methods; to maintain accurate transaction records; and to reconcile financial accounts.
• Regulatory Compliance: To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under Philippine law; to verify your age and eligibility; to generate reports required by PAGCOR; and to cooperate with law enforcement investigations.
• Fraud Prevention and Security: To detect and prevent fraudulent transactions, account takeovers, bonus abuse, collusion, and other prohibited activities; to monitor for unu sual activity patterns that may indicate problem gambling or account compromise.
• Customer Support: To respond to your enquiries, resolve disputes, and provide assistance with your 23ph account and gameplay.
• Platform Improvement: To analyse usage patterns, improve the performance and functionality of the 23ph platform, and develop new features and game offerings.
• Promotions and Communications: To send you promotional offers, bonus notifications, and platform updates where you have opted in to receive such communications. You may opt out of marketing communications at any time through your account settings.
• Responsible Gaming: To monitor account activity for indicators of problem gambling and to enforce deposit limits, self-exclusion, and other responsible gaming measures you have set or that 23ph has applied to your account.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its IRR, 23ph processes your personal data on the following legal bases:

7. Data Sharing and Disclosure

23ph does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data only in the following limited circumstances:

8. Security Measures

23ph implements industry-standard technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption in Transit: All data transmitted between your browser and the 23ph platform is encrypted using Transport Layer Security (TLS) with 256-bit SSL certificates.
• Encryption at Rest: Sensitive personal data stored on 23ph servers, including identity documents and financial data, is encrypted using strong industry-standard encryption algorithms.
• Access Controls: Access to personal data within 23ph's systems is restricted to authorized personnel on a need-to-know basis, enforced through role-based access controls and multi-factor authentication for administrative access.
• Two-Factor Authentication (2FA): 23ph offers 2FA to all account holders and strongly recommends its use for account security.
• Security Monitoring: 23ph employs continuous security monitoring, intrusion detection systems, and regular third-party security audits to identify and remediate vulnerabilities.
• Incident Response: In the event of a data security incident that affects your personal data, 23ph will notify affected players and the National Privacy Commission (NPC) in accordance with NPC Circular requirements for personal data breach notification.

While 23ph takes all reasonable precautions to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your own 23ph account credentials.

9. Data Retention

23ph retains your personal data only for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable Philippine law. The following general retention periods apply:

After applicable retention periods expire, personal data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual. Data retained solely to satisfy legal obligations will not be used for any other purpose.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 23ph:

• Right to Be Informed: The right to know how your personal data is collected, used, stored, and shared — which is the primary purpose of this Privacy Policy.
• Right to Access: The right to request a copy of the personal data 23ph holds about you, together with information about how it is processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data in your 23ph account. You may update most account information directly through your account settings.
• Right to Erasure: The right to request deletion of your personal data, subject to 23ph's obligations to retain certain data under Philippine law (including AML retention requirements for transaction records).
• Right to Data Portability: The right to request a structured, commonly used, machine-readable copy of your account data that can be transferred to another service provider, where technically feasible.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time through your account settings or by contacting 23ph support.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe 23ph has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of these rights, please contact 23ph via live chat on the platform or by email at [email protected]. 23ph will respond to verifiable data subject requests within 15 business days.

11. Cookies and Tracking Technologies

23ph uses cookies and similar tracking technologies on the platform to enhance your user experience, maintain your login session, analyse platform performance, and support security and fraud prevention systems.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using the 23ph platform, though some features may behave differently.

12. Minors and Age Restriction

The 23ph Service is strictly restricted to individuals who are 21 years of age or older in accordance with PAGCOR's minimum age requirements for online gambling in the Philippines. 23ph does not knowingly collect personal data from individuals under the age of 21.

If 23ph becomes aware that personal data has been collected from an individual under 21 years of age, we will immediately suspend the relevant account, void any associated transactions, and delete or anonymise the personal data in question. Parents or guardians who believe a minor has registered a 23ph account should contact support immediately.

13. International Data Transfers

Some of 23ph's contracted service providers — including certain game content providers and technical infrastructure partners — may be located outside the Philippines. Where personal data is transferred to recipients in other countries, 23ph ensures that such transfers are subject to appropriate safeguards, including contractual data processing agreements that require the recipient to maintain protections at least equivalent to those required by the Data Privacy Act of 2012.

23ph will not transfer your personal data to a country whose data protection laws are materially deficient relative to Philippine standards without implementing appropriate contractual or other protections. Where required, 23ph will seek NPC approval for cross-border data transfers in accordance with applicable NPC guidelines.

14. Changes to This Policy

23ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform functionality. Material changes to this Policy will be communicated to registered players via the email address or mobile number on file and/or through a prominent notice on the 23ph platform prior to the change taking effect.

The "Last Updated" date at the top of this Policy reflects the most recent revision. Your continued use of the 23ph Service following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree with any change, you should cease using the Service and may request account closure through your account settings or by contacting support.

15. Contact & Complaints

If you have questions about this Privacy Policy, wish to exercise your data subject rights, or would like to raise a privacy concern, please contact 23ph through the following channels:

• Live Chat: Available 24/7 directly within the 23ph platform. This is the fastest way to reach a support agent for real-time privacy assistance.
• Email: [email protected] — Response time is typically within 24 hours on business days. Please include "Privacy Request" in your subject line.

If you are not satisfied with 23ph's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines through their official government channels.

For questions specifically about these Terms or your account, please also refer to the Terms & Conditions and FAQ pages.